OMB New Uniform Guidance

Transcription

1 ICCCFO Spring 2015 Conference April 8 10, 2015 Oglesby, IL Starved Rock Lodge and Convention Center OMB New Uniform Guidance Wednesday, April 8, :15 pm 4:45 pm Presented by: Katherine Eilers, CPA, Manager NONPROFIT AND GOVERNMENT PRACTICE Reproduction or use of any training materials in this manual, except within a participant s agency without express written permission is prohibited by copyright law.

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3 OMB New Uniform Guidance Trainer: Katherine Eilers, CPA, Manager 1 Materials/Disclaimer Please note that these materials are incomplete without the accompanying oral comments by the trainer(s). These materials are informational and educational in nature and represent the speakers' own views. These materials are for the purchasing agency s use only and not for distribution outside of the agency or publishing on a public website. 2 OMB New Uniform Guidance 1

4 2 CFR Part 200 Table of Contents Subpart A ( ) Subpart B ( ) Subpart C ( ) Subpart D ( ) Subpart E ( ) Subpart F ( ) Acronyms and Definitions General Provisions Pre-Federal Awards Requirements and Contents of Federal Awards Post Federal Award Regulations Cost Principles Audit Requirements 3 Subpart B. General Provisions Review Date OMB will review this part at least every 5 years after 12/26/ Effective Date Federal awarding agencies must implement effective 12/26/2014. Audit requirements effective for fiscal years beginning after 12/26/2014. Non-Federal entities may delay implementation of procurement standards for 1 fiscal year 4 OMB New Uniform Guidance 2

5 Wipfli s Top Changes 1. Internal controls focus in admin requirements 2. Computers as supplies 3. Procurement 4. Recognition of electronic media 5. Cost allocation options 6. No PARs 7. No employee morale 8. Fund raising to support program 9. Family friendly policies 10. Audit threshold changes 5 Subpart D. Post-Federal Award Requirements NEW Internal controls Non-Federal entity must: (a) Establish and maintain a system of internal control that provides for reasonable assurance that the entity is managing the award in compliance with Federal statutes, regulations and the terms and conditions of the award Internal controls should comply with the Committee of Sponsoring Organizations of the Treadway Commission (COSO) (b) Comply with Federal statutes, regulations and terms and conditions of the award 6 OMB New Uniform Guidance 3

6 Subpart D. Post-Federal Award Requirements Supplies (a) NEW Supplies includes computing devices costing less than $5,000 Residual value greater than $5,000 at completion of project, use in other Federal programs; or compensate awarding agency and use for other purposes 7 Procurement regulations 8 OMB New Uniform Guidance 4

7 Subpart D. Post-Federal Award Requirements NEW Methods for collection, transmission and storage of information Should collect, transmit and store award-related information in open and machine-readable formats rather than paper. No need to print electronic records. Can scan paper records if there are quality controls, the electronic records can t be changed and are readable. 9 Subpart E. Cost Principles Direct and Indirect Indirect Costs (f) NEW Any non-federal entity that has never negotiated an IDCR may elect to charge a de minimis rate of 10% of modified total direct costs (MTDC) which may be used indefinitely 10 OMB New Uniform Guidance 5

8 Subpart E. Cost Principles Direct and Indirect Indirect Costs (cont.) (g) NEW Any non-federal entity that has a current federally negotiated indirect cost rate may apply for a one-time extension of the rates in that agreement for a period of up to 4 years Must be approved by a cost negotiator If approved, may not request a rate review until the extension ends At end of extension, must apply for a new rate Subsequent one-time extensions (up to 4 years) are permitted if approved 11 Subpart E. Cost Principles Selected Items of Cost Compensation personal services (cont.) (i) NEW Standards for Documentation of Personnel Services (1) Records accurately reflect work performed (i) Supported by a system of internal controls that assures charges are accurate, allowable and properly allocated (ii) Part of official records of the entity (iii)reflect total activity (iv)include Federal and non-federal activities (v)comply with accounting policies (vii)support distribution to two or more activities or cost objectives 12 OMB New Uniform Guidance 6

9 Definition Cost objective Cost objective means a program, function, activity award, organizational subdivision, contract or work unit for which cost data are desired and for which provision is made to accumulate and measure the cost of processes, jobs, etc. A cost objective may be a major function, a particular service or project, a Federal award, or an indirect cost activity. 13 Subpart E. Cost Principles Selected Items of Cost Employee health and welfare costs (a) Costs in accordance with documented policies for improvement of working conditions, employeremployee relations, health and performance are allowable Costs for improvement of morale specifically excluded 14 OMB New Uniform Guidance 7

10 Subpart E. Cost Principles Selected Items of Cost Fund raising and investment management costs (a) Costs of fund raising including financial campaigns, solicitation of gifts, etc., are unallowable NEW Fund raising costs for the purposes of meeting federal program objectives are allowable with prior written approval 15 Subpart E. Cost Principles Selected Items of Cost Travel costs (c) (1)NEW Temporary dependent care costs resulting from travel to conferences are allowable provided that: (i) Costs are a direct result of travel; (ii) Costs are consistent with the travel policy; and (iii) Costs are temporary during the travel period 16 OMB New Uniform Guidance 8

11 Subpart F. Audit Requirements Audit Requirements (a) Audit required. A non-federal entity that expends $750,000 (NEW) or more during the non-federal entity's fiscal year in Federal awards must have a single or program-specific audit 17 Subpart F. Audit Requirements Major Program Determination (b) Determine Type A Programs Total Federal awards expended Equal to or exceed $750,000, but less than or equal to $25 million Exceed $25 million but less than or equal to $100 million Exceed $100 million but less than or equal to $1 billion Exceed $1 billion but less than or equal to $10 billion Exceed $10 billion but less than or equal to $20 billion Exceed $20 billion $750,000 Type A / B Threshold Total Federal awards expended times.03. $3 million. Total Federal awards expended times.003. $30 million. Total Federal awards expended times OMB New Uniform Guidance 9

12 Summary and Next Steps Learn what new regulations and changes from the current regulations will impact your agency Develop a plan to implement the necessary changes Educate others in your organization on the changes and include them in the planning process Watch for guidance from your funding sources 19 Connect with me: Bring Wipfli to You: Tammy T. Jelinek tjelinek@wipfli.com My Wipfli Access to our experts: Evaluation: Regulation questions Audit Process Human Resource Technology Leadership Thank You! 20 OMB New Uniform Guidance 10